GREECE Law and Practice Contributed by: John C. Dryllerakis, John Papadakis and Nikos Kalantzis, Dryllerakis Law Firm
financial accounts information (incorporated with Law 4378/2016); • Directive 2015/2376/EU, effective from 1 January 2017, which introduced the automatic exchange of information on advance cross-border rulings and advance pricing arrangements (incorporated with Law 4474/2017); • Directive 2016/881/EU, effective from 5 June 2017, which introduced the automatic exchange of infor - mation on the country-by-country report (incorpo - rated with Law 4484/2017); • Directive 2016/2258/EU, effective from 1 January 2018, which introduced the access of tax authori - ties to mechanisms, procedures, documents and information in order to combat money launder - ing from illegal activities (incorporated with Law 4569/2018); • Directives 2018/822/EU & 2020/876/EU, which introduced the mandatory automatic exchange of information on reportable cross-border arrange - ments (incorporated with Law 4714/2020), as well as its Addendum (ratified with Law 5272/2026) • Directive 2021/514/EU, which established the scope and the conditions of the mandatory auto - matic exchange of information reported by plat - form operators (incorporated with Law 5047/2023); and • the Multilateral Competent Authority Agreement on Automatic Exchange of Information pursuant to the Crypto-Asset Reporting Framework (ratified with Law 5273/2026).. Between Greece and other (non-EU) countries, admin - istrative cooperation in the field of taxation is based on the following agreements: • the European Convention on Mutual Administrative Assistance in Tax Matters of 25 January 1988 (as amended in 2010 – ratified with Law 4153/2013), the scope of which covers specific categories of direct and indirect taxes (the Convention pro - vides for three kinds of information exchange, namely: upon request, spontaneous and automatic exchange of information); • the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Informa - tion (ratified with Law 4428/2016), which provides for the exchange of information corresponding to
that defined in the Directive 2014/107/EU, as well as its Addendum (ratified with Law 5272/2026); and • the Multilateral Competent Authority Agreement on the Exchange of (Country-by-Country Reports (ratified with Law 4490/2017), which provides for the exchange of information corresponding to that defined in the Directive 2016/881/EU; and • the Multilateral Competent Authority Agreement on Automatic Exchange of Information pursuant to the Crypto-Asset Reporting Framework (ratified with Law 5273/2026). Between Greece and the US, administrative coopera - tion in the field of taxation is based on the following agreements: • the Agreement to improve International Tax Compliance and to Implement Foreign Account Tax Compliance Act ((FATCA) – ratified with Law 4493/2017); and • the Arrangement on the Exchange of Country-by- Country Reports (ratified with Law 4534/2018), which provides for the exchange of information corresponding to that defined in the Directive 2016/881/EU. 7.2 Exchange of Information Clauses in Tax Agreements Greece participates in the international exchange of tax information under both domestic law and multi - lateral agreements. The country employs automatic, spontaneous and on-request exchange mechanisms, in line with OECD and EU standards. Exchange on request is carried out upon a specific and reasoned request by a foreign competent author - ity concerning identifiable taxpayers and foreseeable relevance. Spontaneous exchange takes place where the Greek tax authorities identify information that may be rel - evant to another jurisdiction, such as adjustments following a tax audit or the granting of cross-border rulings that fall within EU reporting obligations. Automatic exchange of information is implemented extensively under EU law and international stand - ards. Greece participates in automatic exchanges
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